Financial Conflict of Interest applies to a Synthasome associate and the associate’s spouse and dependent children. The associate may wish to consider employment or other significant financial conflict of interests that may apply to their parents, brothers and sisters.

A Financial Conflict of Interest shall be deemed “significant” (Significant Conflict of Interest) if the aggregate interest of the associate, spouse and children represents:

• More than five percent of the outstanding securities of a corporation, or more than $10,000 in value as determined by reference to public prices or other reasonable measures of fair market value;
• Intellectual Property rights (for example, patents, copyrights, and royalties from such rights);
• Ownership in an unincorporated or non-public business;
• Salary or other payments for services (e.g. consulting fees or honoraria).

An associate shall not conduct business on behalf of Synthasome with a relative (including spouse, children, parents, brothers, sisters) or a business with whom an associate or a relative is associated, except where such dealings have been disclosed to the Company and the Company has given its specific approval and authorization. An associate shall not acquire, directly or indirectly, real estate, a significant interest in any business entity, or any other property that such associates knows, or has reason to believe, may be of acquisition interest to Synthasome.

Significant Financial Conflict of Interest does not include:

• Salaries, royalties, or other remuneration from Synthasome
• Any ownership interests in Synthasome;
• Income from seminars, lectures or teaching engagements sponsored by public or nonprofit organizations;
• Income from service on advisory committees or review panels for public or nonprofit entities;
• An aggregate equity interest does not exceed $10,000 and does not represent more than a 5% ownership interest in any single entity;
• Salaries, royalties or other payments that when aggregated for the associate, spouse and children over the next 12 months are not expected to exceed $10,000.

Synthasome engages in substantial research and product development, and as such will frequently perform studies that involve collaborators, contractors and subcontractors. If these personnel are also responsible for design, conduct or reporting of research, then the same Financial Conflict of Interest responsibilities apply to those investigators, and to their spouse and dependent children. In cases where a potential financial conflict of interest may apply, the associate should inform the CEO. It will be the responsibility of the CEO to determine the financial Conflict of Interest of the collaborators, contractors and subcontractors, using the guide as described above.

A Financial Conflict of Interest will be determined by the CEO of Synthasome. In those cases where a significant conflict of interest is identified, the CEO will work the associate, collaborator, contractor or subcontractor to manage, reduce and/or eliminate those conflicts of interest.